1. Written Agreements Between Schools WVASFAA Conference April 1, 2015 Consortiums & Contracts: Craig D. Rorie, Training Officer Federal Student Aid US Department of Education

2. Agenda Definition and purpose Policies applicable to all written agreements Consortium agreement policies Contractual agreement policies Study abroad References and resources 2

3. Consortium Agreement A written agreement between two or more eligible schools 3

4. Contractual Agreement A written agreement between an eligible school and an ineligible school or organization 4

5. Other Definitions Home school: The school where the student is enrolled in a degree or certificate program Host school: The school where the student is taking part of her or his program requirements through a consortium or contractual agreement 5

6. Purpose Consortium and contractual agreements allow students to receive Title IV aid to take advantage of educational opportunities outside of the home school. 6

7. Purpose Study abroad and summer programs Sharing of learning resources in a school’s community Course offerings, fields of study or modes of delivery not otherwise available at the home school ‘Two-plus-two’ and other partnerships to promote bachelor’s degree completion Flexibility for students to live in alternate locations 7

8. General Policies: Consortiums and Contracts 8

9. Scope Agreements can be made broadly, or for an individual student or group of students Agreements can be made for a limited period of time, or can go on indefinitely − Standing agreements need not be renewed unless there is a change in terms 9

10. Academic Credit The home school must give credit for courses taken at schools or organizations included in the agreement − Courses must be applicable to the student’s program Assumption is that the home school accepts the other entities’ standards − Equivalent academic standards − As if the home institution had provided the instruction itself 10

11. Eligibility and Disbursement For calculating Title IV awards, the Costs of Attendance for the home and host schools are combined Disbursements of Title IV aid can be made according to host schools’ payment periods as appropriate 11

12. Satisfactory Academic Progress Home school not obligated to abide by host school satisfactory academic progress (SAP) policies, such as grade point requirements Grades earned at host school are not required to be included in home school’s GPA review for SAP − Credits must be included in quantitative SAP review, such as the percentage of credits attempted that are successfully completed 12

13. Enrollment Status and Reporting Enrollment status is a combination of all concurrent courses that apply to a student’s program, at home and host school(s) − Adjustments may be required if schools award credit differently (see example in 2014-15 FSA Handbook, 3-50) For the National Student Loan Data System (NSLDS) the home school is always responsible for monitoring and reporting enrollment 13

14. Consumer Information Schools must provide information about all written agreements to both enrolled and prospective students − Portion of programs provided at host schools Methods of delivery − Names and locations of host schools − Estimated costs of enrolling in host school courses 14

15. State Complaint Process Contact information for filing a complaint about a school must be provided for each state in which the school operates 15

16. Policies and Procedures Procedures for entering into written agreements with other entities should be included in a school’s policies and procedures manual. − General policies on entering into agreements − Who is responsible for negotiating and updating agreements as needed − Agreement templates used (paper and/or electronic) − Offices of record 16

17. Consortium Agreements 17

18. Individual students or Groups of students Individual schools or Groups of schools Consortium Agreements 18

19. Required Elements Which school is the home school? What are student costs for attending home and host schools? What will be the student enrollment status at the home and host schools? Which school will determine student eligibility and calculate awards? Which school will disburse Title IV aid, monitor eligibility, and return funds if necessary? Which school(s) will maintain records? 19

20. Eligibility and Disbursement Any participating school may calculate awards or make disbursements of Title IV aid without being considered a third-party servicer − School disbursing aid may be different from the school the student is attending Book funds for Pell Grant recipients must be made available by the 7 th day of the payment period of the school disbursing aid 20

21. Ownership If schools participating in a written agreement are owned or controlled by the same person or company: The home school program must be approved by the Department as an eligible program The home school must provide more than 50% of the program 21

22. Recordkeeping School that disburses Title IV aid must maintain documentation of: − Student eligibility − Award calculation − Disbursement information − Return information Documentation may be obtained from other school(s) 22

23. Contractual Agreements 23

24. Contractual Agreements Individual students or Groups of students Individual organization 24

25. Limitations An eligible school may not enter into a contractual agreement with an ineligible entity whose: − Eligibility to participate in the FSA programs has been terminated, revoked, or voluntarily withdrawn − Application for certification or recertification to participate in the FSA programs was denied 25

26. Limitations Under a contractual agreement, the eligible school is always considered the home school − All Title IV calculations and disbursements are made by the home school − All records are maintained by the home school 26

27. Ownership If the home school and ineligible entity are owned or controlled by the same person or company, no more than 25% of a program may be provided by the ineligible school If the home and ineligible institutions are separately owned, the ineligible school may provide up to 50% of a program − If the contracted portion is from 26-50% of a program, then the home school’s accrediting or state agency must confirm in writing that the contract meets its standards 27

28. Study Abroad 28

29. Study Abroad Programs Study abroad programs may be offered using a consortium or contractual agreement − Arrangements with a foreign school are always considered contractual, even if the foreign school is Title IV-eligible − Schools may enter into agreements with organizations that represent multiple foreign schools 29

30. Study Abroad Programs A home school may also send its own faculty and students to a foreign site − This type of study abroad program does not require a written agreement, but the foreign site is considered an additional location that may require approval 30

31. Eligibility and Disbursement Title IV aid must be offered to eligible students for study abroad programs Study abroad programs must apply to a student’s academic program, but need not be required If study abroad costs are higher than typical home school costs, these must be reflected in the Cost of Attendance 31

32. References 32

33. References and Resources Written agreements: General information 34 CFR 668.5 Consumer information34 CFR 668.43(a)(12) State Complaint Process34 CFR 668.43(b) Study Abroad: Student eligibility34 CFR 668.39 Foreign Schools: Dear Colleague Letter GEN-11-18 33

34. References and Resources Federal Student Aid Handbook: Vol. 2, Ch. 2: Written Arrangements Between Schools Vol. 3, Ch. 3: Calculating Pell andIraq & Afghanistan Service Grant Awards Vol. 4, Ch. 2: Disbursing FSA funds 2015-2016 34

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36. Research and Customer Care Center 800.433.7327 fsa.customer.support@ed.gov Reach FSA 855.FSA.4FAA -- 1 number to reach 10 contact centers! Campus Based Call Center eZ-Audit COD School Eligibility Service Group CPS/SAIG Foreign Schools Participation Division NSLDS Research and Customer Care Center G5 Nelnet Total & Permanent Disability Team 36 U.S. Dept. of Education – FSA Contacts

37. Region III Training Officers  Amber Johnson, Training Officer amber.johnson@ed.gov 215-656-5998  Craig Rorie, Training Officer craig.rorie.@ed.gov 215-656-5916 37

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